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Structured Summary of the Tribunal's Order (ITA-TP Nos. 123 & 351/Hyd/2022)

Factual and Procedural Background

These are two appeals (ITA-TP Nos. 123 & 351/Hyd/2022) before the Income Tax Appellate Tribunal arising from orders dated 21/02/2022 and 17/06/2022 passed by the National Faceless Assessment Centre (NFAC) and the Learned Assistant Commissioner of Income Tax, Circle-1, Kurnool, for the assessment years 2017-18 and 2018-19 respectively. The appellant in both matters is Sree Rayalaseema Hi Strength Hypo Limited ("the assessee"); respondents include DCIT, Circle-1, Kurnool and ACIT, Circle-1, Kurnool. The appeals were filed under provisions referred to in the order as "under section1 43(3) r.w.s .144C(13) r.w.s. 144Bo f the Income Tax Act, 1961" and were heard together because the facts and grounds were identical.

Brief factual matrix (as recorded in the order): the assessee is engaged in manufacturing and sale of industrial chemicals, trading in coal and generation of power. It has a captive thermal power plant of 10 MW capacity with an 11 KV distribution system and claimed deduction under section 80-IA in relation to this unit. For AY 2017-18 a return was filed on 28/11/2017. The assessee supplied power to its associated enterprises (AEs) and internal divisions at an effective rate of Rs. 8.74 per unit and used that as the internal CUP (comparable uncontrolled price) for benchmark/ALP purposes. The Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) took a different view on which components should be included in determining the ALP, resulting in adjustments which were given effect to in the NFAC assessment order. The assessee challenged the exclusion of certain components of the tariff and also raised an issue about credit for Minimum Alternate Tax (MAT) in the assessment computation.

Legal Issues Presented

  1. Whether, for the purpose of determining the arm's length price (ALP) of electricity supplied by the assessee's captive power plant to its related parties and divisions (and for allowing deduction under section 80-IA), the appropriate valuation is the rate charged by the State Electricity Board to industrial consumers (i.e., whether the assessee is justified in adopting Rs. 8.74 per unit including various tariff components).
  2. Whether certain tariff components — time of day (TOD) charges, demand charges, penal charges, customer charges, electricity duty, late payment charges and similar heads that appear in State Electricity Board bills — should be excluded from consideration in benchmarking the captive-supply transaction because the captive generator does not itself incur those specific heads of expenditure.
  3. Quantification of MAT credit and interest under sections 234B and 234C insofar as they arise from the assessment computation after giving effect to transfer pricing directions.

Arguments of the Parties

Appellant's Arguments

  • The assessee contended that its internal CUP — the rate at which an unrelated entity (APSPDCL) supplied power to the assessee and to its comparable units — should be the basis for determining the ALP. The internal CUP adopted by the assessee was Rs. 8.74 per unit.
  • The assessee argued that various components present in State Electricity Board bills (such as TOD charges, demand charges, penal charges, customer charges, electricity duty etc.) form part of the effective tariff and ought to be included in the basic tariff when using the CUP method; excluding them improperly reduces the ALP.
  • The assessee relied on several precedents (High Court and Tribunal decisions) in support of the proposition that, where a captive power plant supplies electricity to AEs and a deduction under section 80-IA is claimed, the market value should be the rate charged by the State Electricity Board to industrial consumers.

Respondent's (Revenue) Arguments

  • The Revenue (Ld. TPO and Ld. DRP) argued that many of the additional charges levied by the State Electricity Board (such as collections on behalf of government, electricity duty, demand charges arising from distribution/transmission investment, firm commitment charges etc.) are not costs borne by the captive generator and therefore should be excluded when determining ALP for a captive-supply transaction.
  • The Revenue contended that the TPO's benchmark (average energy charge of Rs. 7.39 per unit; DRP noted slab-based Rs. 7.40) which excluded the other heads was justified.
  • It was also pointed out by Revenue that the assessee had, for a short period, sold surplus power to APSPDCL at Rs. 5.45 per unit (during two months) and that this rate (as conceded by the TPO) could not be treated as an uncontrolled comparable; nonetheless, Revenue relied on the TPO's approach for benchmarking.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Net of Life Sciences Ltd vs. ACIT (2022) 138 Taxmann.com 557 Case concerned supply of power by captive power plant; principle that valuation for captive supply (for 80-IA deduction) should be the rate charged by State Electricity Board to industrial consumers. The Tribunal considered this decision as part of consistent authority supporting adoption of State Electricity Board rates; followed it in allowing the assessee's approach.
Star Paper Mills Ltd vs. DCIT (2022) Taxmann reference in the order Held that when captive power is supplied to AEs and 80-IA deduction is claimed, valuation should be at the rate charged by State Electricity Board to industrial consumers. Cited and applied as supportive authority for adopting the State Board rate (Rs. 8.74) as ALP.
DCIT vs. Vishal Fabrics Ltd (as cited in the order) Related to supply of power by captive plants and valuation methodology (State Board rate as appropriate benchmark). Used to support the view that the assessee's adoption of State Board-like rates is justified.
West Coast Paper Mills Ltd vs. Additional CIT (2014) (Mumbai ITAT) Decision deals with captive supply valuation and use of State Board rate as market value for captive-supplied power. Cited as precedent which, collectively with other authorities, persuaded the Tribunal to accept the assessee's method.
CIT vs. Reliance Industries Limited (2019) 12 Taxmann.com 372 (Bombay HC) High Court authority on valuation of captive-supplied power and relevance of State Board pricing. Followed respectfully; formed part of the chain of higher court decisions the Tribunal considered in favour of the assessee.
CIT vs. Godavari Power and Ispat Ltd (2014) 42 Taxmann.com 551 (Chhattisgarh HC) Held that State Electricity Board rates are to be considered for valuation of captive-supplied power where 80-IA deductions are claimed. Relied upon to support the Tribunal's conclusion that the assessee's rate (Rs. 8.74) should be accepted.
PCIT vs. Gujarat Alkylation Chemicals Ltd (2017) 80 Taxmann.com 722 (Gujarat HC) Authority dealing with captive power valuation and using State Board charges as market value for captive supply. Formed part of the body of authorities the Tribunal followed in allowing the appeals.
CIT vs. Kanoria Chemicals and Industries Ltd (2013) 35 Taxmann.com 566 (Calcutta HC) Addressed valuation of captive-generated power for related-party supplies and accepted State Board rates as relevant market comparables. Applied to conclude that the assessee was justified in adopting the comparable State Board rate.

Court's Reasoning and Analysis

The Tribunal examined the record and the submissions of both sides and proceeded in the following manner (summary strictly reflecting the text of the order):

  1. The Tribunal accepted the admitted factual position that the assessee operates a captive thermal power plant (10 MW) with an 11 KV distribution system and that it supplied power to its own chemical division and certain AEs. The assessee had adopted an internal CUP of Rs. 8.74 per unit based on rates charged by APSPDCL to comparable consumers (rates cited: Rs. 8.98, Rs. 8.82 and Rs. 10.71 per unit for specific comparables).
  2. The learned TPO had taken the view that the Rs. 8.74 per unit includes various components (demand charges, energy charges, fuel charges, hour charges, night unit charges, electricity duty) which should be excluded because the captive generator does not incur these heads; the TPO proposed an average energy charge of Rs. 7.39 per unit. The DRP, on consideration, adopted a slab-based calculation and held Rs. 7.40 per unit.
  3. The Tribunal noted that the TPO himself accepted that the rate of Rs. 5.45 per unit (at which the assessee sold surplus power to APSPDCL for two months) could not be treated as an uncontrolled comparable — i.e., the TPO conceded its non-comparability in that specific respect.
  4. Crucially, the Tribunal reviewed and relied upon a consistent line of authorities (both Tribunal and High Court decisions) which hold that when a captive power plant supplies electricity to AEs and a deduction under section 80-IA is claimed in respect of profits from such activity, valuation of electricity provided to AEs should be at the rate charged by the State Electricity Board for supply to industrial consumers.
  5. Applying these precedents to the admitted facts (the existence of comparable State Board rates and the internal use/supply by the captive plant), the Tribunal concluded that the assessee was justified in adopting Rs. 8.74 per unit as the ALP and that Revenue was not justified in excluding the tariff heads mentioned from the computation.
  6. Because the Tribunal accepted the assessee's position on ALP, it recorded that issues relating to quantification of MAT credit and interest under sections 234B and 234C had become academic and did not require adjudication.
  7. For the second appeal (ITA-TP No. 351/Hyd/2022 for AY 2018-19) the Tribunal noted the facts and issues were identical and applied the same reasoning and conclusions mutatis mutandis, allowing that appeal as well.

Holding and Implications

Holding:

Both appeals are allowed.

Implications (direct consequences as expressed in the order):

  • The Tribunal accepted the assessee's adoption of Rs. 8.74 per unit as the arm's length price for the supply of power by the captive plant to its chemical division and associated enterprises. Consequently, the Revenue's exclusion of various tariff heads from the ALP computation was held to be unjustified.
  • As a result of accepting the assessee's position on ALP, issues relating to the quantification of MAT credit and the applicability/quantification of interest under sections 234B and 234C of the Income Tax Act were rendered academic and were not adjudicated.
  • The Tribunal expressly followed existing High Court and Tribunal decisions on the point and did not purport to lay down a novel legal principle; it applied established authority to the facts before it.

Order pronounced in open court on 26 October 2022. The order was authored per K. Narasimha Chary, JM, with Shri Rama Kanta Panda as Accountant Member.

    Sree Rayalaseema Hi Strength Hypo Limited, Kurnool v. DCIT, Circle -1 , Kurnool

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    IN THE INCOME TAX APPELLATE TR IBUNAL

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    BEFOR E

    SHRI RAMA KANTA PANDA, ACCOUNTANT M EMBER

    &

    SHRI K.NARASIMHA CHARY, JUDICIAL M EMBER

    zΦyÒΦɠÞ ɰ/ ITA-TP Nos. 123 & 351/ Hyd/2022

    (ȑÑÐɟ ÛxÝØ / xAÌssessment Yea2r:0 17-18 & 2018-19) Sree Rayalaseema Hi Vs. DCIT, Circ-le1 Strength HypoL imited, Kurnoo l

    Kurnoo l &

    [PAN No. AKACS1605]E ACIT, Circle-1, Kurnoo l

    yÒɠÙ /ɟ AÎpɶpellant ŢĕÎ ×ɶ / Responden t ȑÑÐɟxʬȎÛØɟ /Í ØAɠɟss essee by :Shri T. Rajendra Prasa,d AR ØɟÅ Ħʬ Û ɟ/ RØeɟvenue by : Shri K.J.Rao, CIT-DR ÞȓÑÛɟ| ¾ɥ ÍɟØɡ¿/Date of hearing : 06/10/2022 ÁɨÝ ¾Ìɥɟ Íɟ/PØroɡn¿ouncement on : 26/10/2022

    zÏɭ /Ü ORDER

    PER K. NARASIMHA CHARY , JM:

    Aggrieved by the orde(sr) dated 21/02/2022 & 17/06/2022, passed by the National Faceless Assessment Centre (NFAC), D(foerlh ithe AY.2017-18) & Learned Assistant Commissioner o Ifn come TaxC, ircle-1, Kurnoo l(for the AY.201-819) ("LAOd".) in tShree R acyaalaseem ao Hfi Strength HypoL imited ("the asseasssesesmee"nt) y eas fr20o17r-1 8 the

    1

    & 2018-19, under section1 43(3) r.w.s .144C(13) r.w.s. 144Bo f the Income Tax Act, 1961 (cofnsoeqrue nst toh thoer ditre cti"onts ohf Heo'b nleA ct"), Dispute Resolution PaneBl,e ngaluru ("DRaPss"es)se, efil ed these appeasl . Since the facts involved in thestwe o appeals, so also the grounds, are identical we deem it just and proper to dispose of thetwseo appeals by way of a common order, with reference to the facts in the lead case for the assessment year 201-178.

    2. Brief facts of the case are that thmea in business of the assessee is manufacturing and sale of industrial chemical, trading in coal and generation of power.T hey have a captive thermal power plant of 10 MW capacityw ith the distribution system of 11 KVa pcacity and in respect of this unit the assessee claimedde duction under section 8-0IA of the Act. For the assessment year 20-1178, return of income was filed on 28/11/2017 declaring an income of R1s6. ,14,94,790-/. 3CEBre port for this year revealed that the assessee entered into specified domestic transaction with their Associated SErene terprises ("AEs"), namely, Rayalaseema Hi Strength Hypo Limited, Sree Rayalaseema Galaxy Projects Private Limited (SRGP PaLn)d TGV Projectas nd Investment Private Limited (TGVPIPL) in respect of sale of power, and Sree Rayalaseema Hi Strength Hypoi n respect of sale of steel at Rs. 8.74 per uAnsits. essee compared the transaction of sale of power with similar 11 KV connection Ts GoVf PIPL, Gouri Gopal Hospital and Service No. 8S3 RoHf HL Power Platnot state that rate per unit of the comparables was in the rangeR osf. 8.82 to Rs. 10.71 per unit as compared toR s. 8.74p er unit at whicht he captive power plant of the assessee tranfesrred power to the AEs .

    3. Learned Transfer Pricing wOasf of icer ("learned TPO"), however, the opinion that the rate adopted by the assesseeR ast. 8.74 per unit includesd emand charges, energy charges, fuel chaprgeea,k hour charges, night unit charges and electricity duty and such chargheasv e to be excluded from consideration. He accordingly proposed the average energy charges at Rs. 7.39 per u naist Comparable Uncontrloeld Price (CUP) . Page2 of 9

    2

    4. Assessee filed objectios nbefore the learned DRP and contended that its internal CUP i.e., the rate at which the n-eolnigible unit and other AEs procured power in an uncontrolled transactiforonm an unrelated entity viz. APSPDCL, was rthigeht basis for determination of Arms Length Price (ALP) .

    5. Learned DRP considered tdhem and charges, calculating the same on the basis of slab rate as per thtaer iff at Rs. 7.40p er unit and holding that the other charges and duties arise due to various reasnoanms,e ly, some are collections on behalf of the Government by DISCO(fuMeSl surcharge and electricity dutys),o me arise due to large investment made in distribution and transmission assetsp ut by the DISCOM for multiple industrial customers (for example demand charges arising out of providing firm commitment of sanctioned power to industrial power unbitsy the distributing company) etc.I n asmuch as the captive power plant tohfe assessee does not incur these expenditaunred commitments, Rs. 7.39 per unit adopted by the learned TPO againRsst. 8.74 per unit adopted by the assessee, is proper .

    6. Pursuant to the directions given by the Ld. DRP, the learned AssessingO fficer of the National Faceless Assessment Centre ("NFAC") passed the final assessment order on 21/2/2022 in accordance with the directions given by the Ld. DRP, but the grievance of the assessee is that while giving effect to the directions of the Ld. PD,R the learned Assessing Officer of NFAC failed to give credit to the MAT while determining the final tax liability.

    7. Hence, the assessese i ni appeal before the Tribunal contending that the assessee did not claim any excess benefit under section 80IAe of th Act, and while determining theA LP in respect of the price for supply of power per unit, various charges like time of the day charges, demand and penal charges c,ustomer charges, electricity duty should have been taken into consideration to form part otfh e basic tariff itself but the authorities Page3 of 9

    3

    erroneously excluded the same while determining the ALP. In support of their contention that if the supply of electricity by one it to other unit of the entity was made at the rate at which thEele ctricity Boardis supplying power, then it meets the ALP requirement, reliance is placed on the decisions reported in net of life sciences Ltd vs. ACIT (2022) 138 Taxmann.com 557, Star paper Mills Ltd vs. DCIT (2022t)a x1m34a nn.com 177, DCIT vs. Vishal fabrics Ltd (2)0 12329 taxmann.com 30, West Coast paper Mills Ltd vs. additional CIT (2014) 5ta2x mann.com 268 (Mumbai ITAT), CIT vs. reliance industries limited (2019) 12 Taxmann.com 372 (Bombay HC), CIT vs. Godavari power and Ispat Ltd (2014) 42 Taxmann.com 551 (Chattisgarh HC), PCIT vs. Gujarat alkylation chemicals Ltd (2017) 80 Taxmann.com 722 u(jaGrat HC), and CIT vs. Kanoria chemicals and industries Ltd (2013) 35 Taxmann.com 566 (Calcu.t ta HC)

    8. Per contra, Revenue relied upon the orders of the authorities below and it is strenuously argued by the Ld. DR that the cost of production of electricity is to be compared with the cost of production of electricity by the state Electricity Boardsa nd inasmuch as the other charges and duties levied by theS tate Electricity Boaradr ise due to various reasons like the collections on behalf of theG overnmentb y this comes, fuel charge and electricity duty, large investments made in distribution and transmission assets incurred by this comes for multiple industrial customers to meet the demand charges arising out of providing firm commitment of sanctioned power to the industrial power units by the distributing company etc., which the assessee is not likely to incur, and, therefore, the authorities below are justified in excluding such charges which are incurred by the State Electricity Boarbdu t not by the assessee. It is the further argument of the Ld. DR tha tthe assessee supplied power to APSPD CRLs .a5t.45 per unit for a period oft wo months during the relevant financial year and therefore, Ld. TPO benchmarking the price per unitR as t. 7.39 is quite justified.

    Page4 of 9

    4

    9. We have gone through the record in the light of the submissions made on either side I.t is an admitted fact that the assessee has been dealing in manufacturing and sale of industrial chemicals, trading in:

    generation and distribution of power and ecmh icasl to the domestic as well as international markets. The assessee also has a caphteivrme at l power plant of 10 MW capacity at Kurnool, in respect of which the deduction under section 8-0IA of the Act has been claimed by the assessee with the distribution system of 11 KV capacity. It is also not in dispute that the assessee entered into spifeic domestic transaction with its AEs, namely, Sh. Rama SeemHaig h-strength Hypo Ltd, Sh. SMR GalaPxyro jects Pvt. Ltd and ATVP rojectsa nd Investments PrivateL td in respect of sale of power.

    10. Dispute in this appeal revolves around the deduction oRfs . 3,75,68,330-/claimed by the assessee under section- IA8 0of the Act in respect of the power generation through thermal sources by adopRtisn .g

    8.74 per unit as ALP for supply of power to its chemical division and other AEs .It is not in dispute that the stae power distribution company charged Rs .8.98 per unit from TGVP rojecta nd Investment Private Limite,d Rs .8.82 per unit from Gauri Gopal Hospital anRds .10.71 per unit for service No. 583 of SRHHL plant un it.

    11. Insofar as the assessee supplying poweRr sa .t5 .45 per unit for a period of two months till 25/06/2016 is concerned, it remains undisputed that such price was fixed in thfien ancial year2 015-16 and in respect of the surplus power generate, dbased on a sho-rtterm tender invitation by the APSPDC, Lunder the circumstances that APSPDCL is the sole monopoly in generation, procurement and distribution of power in the area and the assessee being a privaeten terprise had to supply surplus power to the State Electricity Boaradn d therefore, there was no option available to the assessee but to sell the same at the price prescribed by the APS APsD aC L. matter of fact, Ld. TPO on a consideration of the submniss mioade by the Page5 of 9

    5

    assessee, agreed with the assesasnede recorded that the rate oRf s .5.45 cannot be controlled transactio n.

    12. Now coming to the transactionit is submitted by the assessee in respect of TGVP rojectsa nd InvestmentsP vt. Ltd, Gauri Gopal Hospital and SRHHL, as comparable transactions, rate per unit charged by APSPDCL in respect of TGVPIPL Riss .8.98, in respect of Gauri Gopal Hospital itR is .

    8.82 and in respect of SRHHL iRt sis .1 0.71. Basing on these 3 transaocntsi the assessee concluded that the rate per unit is abRosu .8t .82 to Rs .10.71 and, therefore, the average aRt s .8.74 per unit is taken to benchmark the transaction. Insofar as these rates are concerned, Ld. TPO does not dispute the same.A ccording to ht e Ld. TPOa, ssessee is not entitled to claim the inclusion of the TOD charges, demand charges, penal demand charges, electrical duty, customer charges and late payment charges which the state electricity board collects from the consumer, since the assee dsoses not incur any expenditure relevant to such charges being a captive power plant.

    13. It is relevant to note here that the assessee does not claim late payment charges A. ccording to the assessee while adopting CUP method, the price at which the state Ecletricity Board adopted while supplying power to the assessee has to be considered instead of excluding so many charges levelled by theS tate Electricity Boardto its consumers, more particularly to the assesse. Eeven in respect of the chemical division of the assessee in question, it procured power from the thermal divisioRn sa .t

    8.74 while the same chemical division procured power from the APSPDCL at Rs .10.71 per unit. Insofar as this fact is concerned, neri the Ld. TPO nor the Ld. DRP dispute the sam e.

    14. Coming to the case law relied on by the assessee, in the cases of Star paper mills Ltd (supra), Vishal fabrics Ltd (supRreal)ia, nce Industries Limited (supra), GodavarPi ower and Ispat Ltd (supra), GujratA lkalis and ChemicalsL td (supra) and Kanrioa Chemicalsa nd IndustriesL td (supra) are Page6 of 9

    6

    concerned with the supply of power generated by the captive power plants. In all these cases, and more particularly in Ntheector Lifesciences Ltd (supra), Star paper Milsl Ltd (supr)a, West Coast paper Mills Ltd (sup),r a GodavariP ower (supra), Gujrat Alkalis( supra) and KanodiCa hemicalsit is specifically held tha wt hen an assessee seutp a captive power generation plant and provided electricity to its AEs ancdla imed deduction under section 80-IA of the Act, in respect of the profits arising out of such activity, the valuation of the electricity provided to the AEs should be at rate at which the State Electricity Boardch arges for supply of electricity to the industrial consumers .

    15. On the face of the admitted fact that the Ld. TPO himself conceded that the rate at which the assessee supplied the power to the APSPDCL during the financial year 201-156 at Rs. 5.45 cannot be an uncontrolled transaction, the Ld. TPOa ncnot ignore the transactioans submitted by the assessee between TGPVro jects, Gauri Gopal Hospital and SRHHL with the APSPDCL Rats .8.98, Rs .8.82 andR s .10.71 per unit cannot be ignore. dAt the same time the consistent view taken by the higher judl ifcoiara and also the Tribunal in the cases referred to by the assessee is to the effect that when the assessee had set up a captive power generating unit and provided electricity to its AEs and claimed deduction under sectio-InA 8 0 of the Act in respect opf rofits arising out of such activity, for the purpose of such deduction the market value of power supplied by the assessee to its AEs should be computed considering the rate of power charged by the State Electricity Boarfdo r supply of electricity to indutrsial consumers .

    16. We, therefore, respectfully following the decisions of various Hon'ble High Courtsin the case ofR eliance Industries Limite(ds upra), GodavariP ower and Ispat Ltd (supra), GujraAtl kalis and ChemicalsL td (supra) and KanoriaC hemicalsa nd Industries Ltd (supra) are of the considered opinion that the assessee is justified in adoptingA tLhPe o f the electricity supply bites captive power generation plant to its AERss a.8 t. 74 and the Revenue is not jufsietid in excluding certain heads of charges from Page7 of 9

    7

    out of it. With this view of the matte, rwe allow the grounds of appeal on this aspect .

    17. In view of our finding in the preceding paragraphs, issues relating to the quantification of the MAT credit and interes tunder section 234B and 234C of the Act are academic in nature and need not be adjudic ated.

    18. Since the facts of ITTAP N o. 351/Hyd/2022 for the assessment year 2018-19 are identical to one as decided by us in ITTPAN o. 123/Hyd/2022 (supra) for thea ssessment year 2107-18 and, therefore, our findings in the said appealm, utatis mutandis, would apply to this appeal as well. Hence, this appeal of assessee is also allow ed.

    19. In the result,b oth the appeals of the assessee are allow ed. Order pronouncedn i the open court on this th e26thday of October, 2022

    S d /- S d /-

    (RAMA KANTA PAND A ) (K. NARASIMHA CHA RY)

    ACCOUNTANT MEMB E R J UDICIAL MEMB ER

    Hyderabad , Dated:2 6/10/2022

    TNMM

    Page8 of 9

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    Copy forwarded to :

    1. Sree Rayalaseema Hi Strength HLypimoi ted, 40-304, KJS Comple, x Bhagya Nagar, Kurno ol.

    2. DCIT, Circ-le1, Kurnool .

    3. ACIT, Circle-1, Kurnoo.l

    4. NFAC, Delh i

    5. The Dispute Resolution Panel (DRBPe),n galuru.

    6. The Director of Income Tax (IT & TPH)y,d erabad .

    7. The Addl. Commissioner of Income Tax (Transfer Pricing), Hyder abad.

    8. DR, ITAT, Hyderaba d.

    9. GUARD FIL E

    TRUE COP Y

    ASSISTANT REGIST RAR

    I TAT, HYDERAB AD

    Page9 of 9

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    Sree Rayalaseema Hi Strength Hypo Limited, Kurnool v. DCIT, Circle -1 , Kurnool
    (Oct 26, 2022)